Housing targets: new numbers, familiar questions
The Draft Plan sets an annual housing target of 55,800 homes (558,000 homes by 2037), a notable reduction from 88,000 and a welcome acknowledgement of the reality of the substantial gap between targets and deliverable numbers. The fact that London will be unable to meet its own housing need for the next ten years is a significant position for the Draft Plan to take. Nonetheless, in considering the levels of housing delivery that have been achieved in recent years, we reluctantly agree with the statement in the evidence base “it is important that when setting requirements at the strategic scale the London Plan is not unduly optimistic as this would set LPAs up to fail”. Still, this position will no doubt be heavily scrutinised during the consultation process.
At a Borough level, the highest housing requirements are allocated to Ealing, Greenwich and Southwark. By contrast, some established growth areas, including Newham, Tower Hamlets and Barking & Dagenham, are assigned lower requirements than previously anticipated, a shift that may surprise some observers given the scale of London's housing need.
The targets are not just theoretical; they have practical importance given that failure to deliver triggers the ‘presumption of sustainable development’ (in line with Paragraph 79 of the NPPF).
For Boroughs with higher targets, unless they are politically opposed to meeting them, we would expect (and have already seen) a push for greater density on sites. However, we have reservations about the ‘Optimisation Framework’ which sets recommended density ranges, albeit allowing for ‘site-specific’ responses, including greater height and densities in ‘better-connected locations’. Drafting of the policy and application of the framework will need to be very clear to avoid unintended consequences, including arbitrary caps on density, even where this does not give rise to material impacts on specific sites.
Affordable housing: flexibility or a planning maze?
The Draft Plan takes a new approach to affordable housing, clearly a key Mayoral priority. Boroughs have now been given more specific targets:
- 35% - Camden, Islington, Hackney, Tower Hamlets, Southwark, Lambeth, Wandsworth, Hammersmith and Fulham, Kensington & Chelsea, Westminster and Richmond
- 25% - Ealing, Lewisham, Greenwich, Newham, Waltham Forest, Haringey, Brent, Merton
- 20% - Hounslow, Kingston, Hillingdon, Enfield, Barking, Barnet, Bromley, Harrow, Sutton, Redbridge, Croydon, Havering and Bexley
These targets then get lowered if the proposals provide 100% social rented homes or 100% key worker living rent homes in the case of Build-to-Rent proposals.
For the above sites the following affordable housing targets apply:
- Green Belt land – 50%
- Public Sector land – 40%
- Industrial land – 35%
On top of this, the Draft Plan introduces circumstances in which the thresholds for Green Belt and public sector land are altered which include proposing ‘significant transport infrastructure delivery’. The Green Belt target then reduces to 35%, and the public sector target reduces to 25%.
This approach is intended to match policy requirements with deliverable levels of affordable housing and to avoid lowering the requirement in areas where the Greater London Authority considers this is not necessary. However, we have concerns that this is too prescriptive to reflect ever-changing market conditions and that it will create boundary distortions. In addition, with the overall housing target reducing, the approach to affordable housing does not get the same reduction. This leaves us questioning whether the approach to delivering affordable housing is already flawed.
Added complexity is also created by the current Support for Housebuilding LPG, which remain in place until March 2028. A recent scheme we have advised on is the redevelopment of the Former GSK Headquarters in the London Borough of Hounslow, which secures 22% affordable housing in line with the emergency measures. We are also aware of c. 20 other schemes looking to utilise these measures. Given the number of schemes using the measures positively, we would argue that these measures should have been made permanent within the new Plan, rather than reinstating a potentially unrealistic 25%-35% requirement in more centrally located Boroughs.
Recent evidence would suggest that if the affordable housing policy is too complex or sets too high a requirement, applicants will progress with site-specific viability to ensure deliverable schemes or be left with undeliverable schemes that cannot viably achieve the affordable housing levels committed in their permissions. Recent appeal decisions, and call-ins on major strategic schemes, such as the Canada Water Scheme, which proposes 9% affordable housing, demonstrate that deliverable affordable housing levels are considerably below the draft targets.
Tenure mix: simpler on paper?
The proposed tenure mix, a 60:40 split between social rent and intermediate, at first glance represents a welcome simplification of the existing 30% social rent, 30% intermediate and 40% locally determined.
In theory, this would provide greater certainty, and the increased proportion of intermediate housing is positive, recognising the growing number of Londoners who are priced out of home ownership and rentals but do not qualify for social housing.
However, a London-wide tenure split does not allow flexibility to adapt to local needs, which risks navigating weight to be attributed to the conflicting London and Borough policy. In our view a 10% difference is not a strategic matter.
Design standards: evolution rather than revolution
The Draft Plan largely retains London's strong emphasis on design quality, although there are some welcomed refinements which include:
- A reduction in minimum floor-to-ceiling heights to 2.4 m for at least 75% of the GIA, though it’s not clear that this is a particular concern for housebuilders.
- A revised approach to blue-badge parking provision (the need to demonstrate how an additional 7% of dwellings could be provided in the future falls away).
- Adopting the reduced cycle parking standards from the Support for Housebuilding LPG.
While none of these changes are transformative individually, collectively they can have an impact on scheme viability, unit numbers and delivery timescales. The changes go some way in unlocking delivery. However, some onerous provisions remain, such as the need for family housing to be located in the first 6-storeys of a residential development and continued reference to dual aspect. Arguably, these are not strategic matters and do not need to be in the strategic plan.
Green Belt: the most contentious housing battle begins
Draft Policy PV7 allows release of Green Belt land in areas deemed a ‘broad location for growth’ – these sites could look to deliver 56,100 homes[3] and include areas such as Croydon-New Addington, Dagenham, Mill Hill, Barnet and Crews Hill. The Draft Plan also introduces design criteria (Box PV7B and Table 6.3) for development in the Green Belt. Although, this means utilising Green Belt to only unlock c. 10% of the Draft London Plan’s 558,000 housing target – many would question if this lever should be pushed further to best achieve housing delivery and move the dial closer to the 880,000 objectively assessed housing need figure.
However, not all Boroughs are supportive of Green Belt release, particularly not at the scale required to deliver a meaningful amount of housing. The change to Green Belt policy has already been challenged by Barnet[4] and Croydon Council[5], arguing development should be focused on brownfield land and that local authorities should have the say on Green Belt boundaries. Enfield is revisiting its Green Belt release sites following a change of administration. With this new approach we do expect protracted local opposition, legal challenges and policy disputes.
Late-stage reviews remain: an opportunity missed?
The retention of late-stage viability review mechanisms (as per draft Policy HN3) remains a concern for many investors and developers.
Whilst the rationale for review mechanisms is understandable – namely, to capture future value uplift where market conditions improve – they frequently introduce uncertainty in practice. This uncertainty does not necessarily translate to materially higher affordable housing delivery.
As a result, this often acts a blocker to development. It is difficult to fund a scheme with unknown liabilities. Moreover, the mechanism only works one way. We recommend the removal of this requirement as a significant move to unlock housing delivery.
Final verdict: progress but not a delivery revolution
The Draft London Plan is clearly intended to unlock housing delivery. However, the Plan introduces new layers of complexity which may have unintended consequences. These include a lack of responsiveness to market conditions and creating different requirements in different Boroughs, leading developers to focus in certain areas which are not necessarily those with the highest targets. Whether the Borough accept the specific approach in their areas also remains to be seen.
The broader challenge is that planning policy alone cannot solve London's housing crisis, and if a complex approach is not the right approach, may further constrain it. The market context remains difficult, build costs remain elevated, funding remains constrained and viability continues to be stretched.
The Draft London Plan will ultimately be judged on whether it creates the certainty and flexibility necessary to unlock real delivery.
For all its merits, there remains a lingering question: at a time when the industry is calling for clarity and certainty, has London created a more pragmatic planning framework or simply a more complicated one?
If you would like to discuss how the London Plan impacts specific sites, please get in touch with Oliver Jefferson, Samuel Brown or Alice Young-Lee.
5 August 2026
[1] www.london.gov.uk/sites/default/files/2026-07/Draft%20London%20Plan%202026%20web%20version.pdf
[3] data.london.gov.uk/download/20gq8/w7w/2026%20London%20SHLAA%20Final%20Report.pdf
[5] news.croydon.gov.uk/croydon-council-to-oppose-draft-london-plan-and-defend-boroughs-green-belt/
